Montgomery v. Caribe Transport II, LLC

AI-Generated Summary

Petitioner Shawn Montgomery suffered severe injuries, including leg amputation, when his stopped tractor-trailer was struck by a truck driven by respondent Yosniel Varela-Mojena in Illinois; Varela-Mojena was transporting plastic pots for motor carrier respondent Caribe Transport II, LLC, with shipment coordinated by broker respondent C.H. Robinson Worldwide, Inc.
Montgomery sued respondents in federal district court, alleging C.H. Robinson negligently hired Varela-Mojena and Caribe Transport despite Caribe's poor Federal Motor Carrier Safety Administration safety rating (e.g., deficiencies in driver qualifications, hours of service, maintenance, and crash rate), making crashes reasonably foreseeable.
Procedural History: District Court (S.D. Ill.) held claim preempted by Federal Aviation Administration Authorization Act (FAAAA), 49 U.S.C. §14501(c)(1), and outside safety exception; Seventh Circuit affirmed per Ye v. GlobalTranz Enterprises, Inc.; Supreme Court granted certiorari to resolve circuit split on whether FAAAA safety exception permits negligent-hiring claims against brokers.

Primary Question: Whether the FAAAA's safety exception, §14501(c)(2)(A), permits state negligent-hiring claims against brokers like C.H. Robinson for selecting unsafe motor carriers, or if such claims are preempted by §14501(c)(1).
Nature: Statutory interpretation of FAAAA, which preempts state laws "related to a price, route, or service" of motor carriers/brokers in property transportation, but excepts state "safety regulatory authority... with respect to motor vehicles."
Parties' Arguments: Montgomery: Claim falls within safety exception as it "concerns" motor vehicles via duty of care in hiring risky contractors. Respondents/U.S.: Preempted; exception does not cover brokers (no surplusage/anomaly with other provisions); would swallow preemption rule.

Author & Type: Justice Barrett, for a unanimous Court.
Holding: A negligent-hiring claim against a broker for selecting an unsafe carrier to transport goods is not preempted by the FAAAA, as it falls within the safety exception preserving state authority to regulate safety "with respect to motor vehicles," §14501(c)(2)(A).
Legal Reasoning:
Assumes (without deciding) §14501(c)(1) would otherwise preempt; safety exception saves claims via ordinary meaning of "with respect to" as "concerns" (Dan's City Used Cars, Inc. v. Pelkey); "motor vehicle" defined in §13102(16) as vehicles used in highway transportation.
State common-law duties (e.g., Restatement (Second) of Torts §411) are "safety regulatory authority"; claim "concerns" trucks transporting goods, as broker's duty ties to carrier safety ratings and crash risk.
Rejects counters: Exception saves only safety-related subset of preempted claims (not prices/routes/services); no surplusage (overlaps inherent); §14501(b)(1) anomaly (no safety exception for intrastate brokers) yields to §14501(c)(2)(A) text.
Disposition: Judgment reversed and remanded.

Justice Kavanaugh (joined by Justice Alito): Agrees claim not preempted; case "closer" than majority suggests, acknowledging strong lower court points and broker arguments (e.g., insurance dichotomy, intrastate anomaly, federalism concerns).
Reasons: Textual elasticity of "with respect to motor vehicles" resolved by context—economic deregulation preserved state tort safety regime; no federal broker safety rules; tort incentivizes safe selection without routine liability (reasonable diligence/proximate cause defenses); brokers' litigation/insurance costs legitimate but do not override structure allowing suits against trucking companies.

Resolves circuit split, enabling state negligent-hiring torts against brokers selecting unsafe carriers, reinforcing state police power over trucking safety without undermining FAAAA's economic deregulation of prices/routes/services.
Clarifies "with respect to motor vehicles" broadly encompasses claims "concerning" transport vehicles; distinguishes broker liability (tied to vehicle safety) from preempted economic rules; leaves intrastate broker preemption intact, preserving traditional common-law role in accident prevention amid ~5,000 annual truck fatalities.

This summary was generated by AI and may contain inaccuracies. Refer to the official source document for the authoritative text.

Key terms: Negligent Hiring, Trucking Brokers, Safety Exception